WQ0005555_Staff Report_20181211

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December 11, 2018
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WO, Non -Discharge Unit Application No.: W00005555
Attn: Tessa Monday Facility name: Weyerhaeuser Elkin, WW Irrigation System
From: Patrick Mitchell
Winston-Salem Regional Office
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I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: December 5, 2018
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Dennis Atkinson and their contact information: (336) 526 - 6437 ext.
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Dennis Atkinson Certificate #:SI-15574 Backup ORC: Gerald Nowlin Certificate #:SI-28047
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ® No
If no, please explain: High strength wastewater; system will be more adequate to handle high strength WW when
the facility is connected to public sewer (YVSA) and the spray is no longer the primary means of disposal Also
the new WWTFs will produce a better -quality effluent that can be routed to the spray_
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.): The facility has installed a lot of new WW treatment units This was done to meet the pretreatment
reduce the use of the spray system allow the impacted fields to recover, and primarily discharge to public sewer.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ® No
If no, please explain: The impacted irrigation zones are being worked on (soil treatment, till & reseed). Currently
they can not irrigate these zones. Facility utilizing pump n haul until repairs complete or connection to YVSA.
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
FORM: WQROSSR 04-14 Page 1 of 3

9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: As described above, there are a number of new W W treatment units and changes in flow
direction. An updated system plans with flow direction is needed
10. Were monitoring wells properly constructed and located? ® Yes ® No ❑ N/A
If no, please explain: Construction appears ok. Two of the MWs (MW-4 & 10) are now adjacent to the newer
impact spray zones and therefore within the review boundary. WSRO to continue to closely monitor these wells
and require new downgradient wells if necessary.
11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
Note: The coordinates appear to be correct, but there are a lot of wells listed that do not exists
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: Continued high strength wastewater on NDMRs,
impacted soils in the spray zones from annual soil sampling, and NDARs reporting significantly reduced
irrigation rates as result.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
14. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
® Noncompliance ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? ® Yes ❑ No
Note: Previous NOVs have prompted the Permittee to add new W WTF and connect to public sewer.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item IReason
Updated WWTF Tans New WW treatment units, modifications to the lagoon units, and new flow
The "Reverse Osmosis System" includes 2 sand filters, two reverse osmosis
Revised system description units, a UV disinfection unit, et. Permittee inidcated that all these units are part
of the "Reverse Osomosis System". Add to description or obtain detailed set of
plans showing all
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
5. Recommendation: ® Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
FORM: WQROSSR 04-14 Page 2 of 3

6. Signature of report preparer:
Signature of regional supervis
Date: December 11, 2018
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On December 5, 2018 WSRO staff conducted an inspection of the subject facility. Mr. Dennis Atkinson accompanied
staff on the inspection. Below is a summary items noted during the inspection.
1. As described above, a number of new treatment units have been installed, alterations to the lagoons and changes in
flow direction. In addition, the domestic waste is no longer tied to the spray system and is already discharging to
YVSA. As described during the inspection; the new treatment units will primarily be used to produce high quality
effluent discharging to YVSA. The facility intends to only use the spray when or if the WWTFs have an upset.
Therefore, when the spray is utilized, wastewater strength will likely continue to be high. Significantly reducing the
use will aid in the impacted zones recovering. It should be noted that the facility can divert the high quality effluent
from the new units to the spray if desired. However, they indicated that this will not typically be done.
2. As a result of the additions and modifications to the W WTF listed in # 1 above, an updated set of plans with flow
directions is needed.
3. As described above, the Reverse Osmosis System contains additional units not provided in the updated system
description. It is recommended that those units be included in the system description or a detailed set of plans be
obtained that shows all the units for that "RO system". Again, the Permittee indicates that they typically will not be
using this RO System to produce effluent for spray, but it can be if desired.
4. The connection to YVSA sewer has been completed. The domestic waste is already discharging to sewer. However,
the facility is waiting on the Pretreatment Permit to be issued by YVSA before they are allowed to start the
discharging industrial waste into the sewer. Reportedly this should be completed any day.
5. The facility has had issues with freeboard exceedances. This is due to reduced spray system use. The facility has
obtained a pump and haul permit from the Division and utilizes it for disposal as needed.
6. Monitoring wells #4 and # 10 are no longer near the review boundary. Those wells have impact spray heads installed
near them following a previous major modification. WSRO to continue to monitor those wells and require
replacement downgradient wells if necessary.
7. The cover letter included with the application for permit renewal indicated they would like to close out some of the
older spray zones. However, during the inspection it was unclear which zones or how many they want to close out.
Recommended the Permittee make a formal request for zone removal when they decide in more detail what they
want to do. This likely will impact the permitted daily flow for the spray system. Recommend renewing permit
without zone removal or altered daily flow, unless they provide additional information with a specific request for
such. During the inspection, the Permittee indicated they will review this in more detail when fully operational with
YVSA sewer.
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